What You Need to Know
- Susan Schroeder, now a partner at WilmerHale, weighs in on what early enforcement actions could look like.
- FINRA will likely work in tandem with the SEC, she says.
- Don’t miss the full episode of the Human Capital podcast Friday.
Susan Schroeder, former chief of the Financial Industry Regulatory Authority’s enforcement division, told Human Capital Wednesday that she sees enforcement actions related to Regulation Best Interest compliance “coming soon” — likely this year.
“In terms of how aggressive they’ll [the Securities and Exchange Commission will] be, I guess it depends a bit on what we think of as ‘aggressive,’” said Schroeder, partner at the law firm WilmerHale and vice chair of its Securities & Financial Services Department.
“Early enforcement actions will be predicated on things like policies and procedures, but by past SEC standards, that is very aggressive.”
If early enforcement actions “are predicated on things like inadequate training or failures to have policies and procedures, from a legal theory perspective, that’s aggressive,” Schroeder said.
Will the SEC and FINRA work in tandem to bring enforcement actions?